International Tag Co. v. Commissioner

*311OPINION.

Phillips :

The claim of petitioner that it falls within section 327 of the Revenue Act of 1918 and is entitled to a computation of its tax under section 328 is based on the ownership of two patents, *312together with certain secret mechanical devices and processes used in the conduct of its business which it claims do not appear in its invested capital but which are responsible for part of its income, A balance sheet submitted in evidence shows that patents were carried at $10,294.10 as of January 1, 1920, and at $8,823.51 as of December 31, 1820. The difference of $1,470.59 must represent…